Anthony A. v. Commissioner of Correction, 326 Conn. 668

Summary

The Connecticut Supreme Court held that a habeas petitioner sufficiently alleged a protected liberty interest when he claimed that the Department of Correction wrongfully classified him as a sex offender and required sex-offender treatment or risked loss of parole eligibility, supervised community release, and good-time credits. Applying the stigma-plus test, the court concluded that the alleged false sex-offender classification was uniquely stigmatizing and that the resulting consequences constituted a major change in confinement conditions amounting to a grievous loss. The court affirmed the Appellate Court’s reversal of the habeas court’s dismissal for lack of subject matter jurisdiction.

Holdings

1. The petitioner's allegations that he was wrongfully classified as a sex offender and that he faced forfeiture of parole eligibility, community release, and good time credits if he refused sex offender treatment were sufficient to allege a protected liberty interest under the stigma plus test, conferring subject matter jurisdiction on the habeas court.

Questions Presented

1. Whether an inmate's allegations of wrongful sex offender classification and resulting negative consequences sufficiently allege a protected liberty interest under the stigma plus test to confer subject matter jurisdiction on the habeas court.

Disposition

affirmed